Transcript Slide 1

The Ground Water Rule (GWR)
General Rule Requirements
40 CFR 141.400 thru 141.405
Arizona Department of Environmental Quality
August 2009
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General Rule Requirements
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Purpose of Rule/Relationship to TCR
Applicability
Basic Requirements
Triggered Source Water Monitoring/Representative
Monitoring Plan
Additional Source Water Monitoring
Assessment Monitoring
Sanitary Survey Requirements
Corrective Action Requirements
Compliance Monitoring
Compliance Dates Associated with the GWR
Violations Associated with the GWR
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Primary Purpose
Require Source
Water
Monitoring
Viruses
Protect Public
Health
Bacteria
Require
Corrective
Action If
Necessary
Identify GWSs
At-Risk To
Fecal
Contamination
Identify
Significant
Deficiencies
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Relationship with the TCR
The GWR triggered sampling is sparked by a
positive ROUTINE TCR sample or
INCREASED ROUTINE TCR sample and NOT
any positive repeat TCR sample.
It is only triggered by monitoring conducted
under 141.21 (a), not (b).
For more information on the TCR see
Total Coliform Rule: A Quick Reference Guide
Available on EPA’s Web site at:
www.epa.gov/safewater/disinfection/tcr/pdfs
/qrg_tcr_v10.pdf
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To Whom Does the GWR Apply?
1
All PWS
Systems
relying
100% on
ground
water
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Consecutive
PWS
receiving
100%
finished
ground
water
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Mixed
surface and
ground
water
systems*
* Unless combined with surface water (SW) or groundwater under the direct
influence of surface water (GUDI) prior to treatment (then the Surface Water
Treatment Rule applies)
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What are the Basic
Requirements?
2
1
Sanitary Surveys
(w/8 elements)
of all GWSs
3*
Correction of
Significant
Deficiencies
Source Water
Monitoring
4*
5
Treatment/
Elimination of
Fecal
Contamination
Compliance
Monitoring
*Provisions
3 and 4 =
corrective
actions
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The path you take is based
upon if you have 4-log
removal or not.
4-log
Treatment
TCR +
Result
Triggered Source
Water Monitoring
Additional
Monitoring
Corrective
Actions
Compliance
Monitoring
Sanitary
Survey
Assessment
Monitoring
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Path #1
If you do NOT have 4-log
removal…
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Source Water Monitoring
Scenarios

Two possibilities:
TRIGGERED (then maybe Additional)
SOURCE WATER MONITORING
ASSESSMENT SOURCE WATER
MONITORING
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What is Triggered Source Water
Monitoring?
GWSs must conduct triggered source
water monitoring if they:
Are NOT conducting GWR compliance monitoring
for their 4-log treatment
Are notified of a TC+ TCR sample
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Sampling Requirements

PWS must:
– Collect a minimum of 1 sample per
ground water source within 24 hours of
learning of the total coliform positive
result
– Analyze sample(s) for fecal indicator
(E. Coli, enterococci, or coliphage)
– Provide public notification of fecal
indicator-positive source water sample

Extension of 24-hour time limit
– State determines exceptions/new time
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Triggered Source Water Monitoring
Consecutives and Wholesale Systems:
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When a consecutive system is notified of a
TC+ sample in the distribution system (DS),
they must notify the wholesale system within
24 hours.
The wholesale system then has 24 hours to
collect a source water sample.
If the wholesale system is positive, they must
notify all consecutives within 24 hours.
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Triggered Source Water
Monitoring Representative
Sampling Plan
(this
is
optional)
 For multi-source systems
– Identify ground water sources that are representative of each
monitoring site in the system’s TCR site sampling plan.
– In AZ, the PWS must submit the plan to the state by August 31,
2009 for approval prior to December 1, 2009.

ADEQ also wants the GWSs to provide:
– Map of the water system, including:
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Location of ground water sources
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Location of pressure zones
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Location of storage facilities
– Written explanation of how they know which well feeds which
section of the distribution system
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Systems Serving < 1,000
People

GWS may use a TCR repeat sample to
satisfy the GWR triggered source water
sample requirements if:
– State allows TCR repeat samples to be taken at
the source
AND
– State approves use of E. coli as fecal indicator
under the GWR and lab uses one of the GWR E.
coli methods
AND
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– GWS serves < 1,000 people
Additional Source Water Sampling
Positive Fecal Indicator in Source Water:
– If the TRIGGERED sample is Fecal Indicator Positive, then the
PWS must collect 5 additional source water samples from the
same source for the state-specified FI within 24 hours unless
immediate CA is required by state/regulatory agency.
– If any of the five additional samples tests positive, the PWS must
notify the state/regulatory agency, the public and comply with
the treatment technique requirements which requires the state
to take one of four corrective actions.
– A PWS must respond to any fecal indicator + sample using an
approved corrective action.
– A Tier 1 Public Notice (PN) is required when any triggered
source water sample is fecal indicator+.
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Assessment Source Water
Monitoring

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
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States/regulatory agencies may require GWSs that
are most susceptible to fecal contamination to
conduct assessment monitoring.
Usually once or twice a month for twelve months.
Assessment source water monitoring samples
cannot be used to satisfy TCR routine or repeat
sampling. But assessment monitoring can be used
to meet triggered source water monitoring
requirements.
Tools to identify high risk GWSs:
– Hydrogeologic sensitivity assessments
– Source water assessments
– Wellhead protection plans
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– Historical monitoring data
What are the Sanitary Survey Requirements?
Must include 8 elements
1)
2)
3)
4)
5)
6)
7)
8)
(where applicable):
Source
Treatment
Distribution system
Finished water storage
Pumps, pump facilities, and controls
Monitoring, reporting, and data verification
System management and operation
Operator certification
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Significant Deficiencies
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Are deficiencies that may cause, or have the
potential to cause, the introduction of
contamination into the finished water
Include deficiencies in:
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Design
Operation
Maintenance
Failures or malfunctions of source, treatment,
storage, or distribution system
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Source
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Well in flood zone
Improperly constructed well (e.g., improper
well surface or subsurface seal)
Spring boxes that are poorly constructed
and/or subject to flooding
Well is located near a source of fecal
contamination (e.g., failing septic system or
a leaking sewer)
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Treatment
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Inadequate application of treatment
chemicals (e.g., disinfection contact time is
inadequate)
Lack of redundant mechanical components
where disinfection is required
Unprotected cross-connections with
treatment chemical system
Inadequate treatment process monitoring
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Distribution System
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

Situation in which negative pressure
can result in contamination entering
distribution pipes
Inadequate disinfectant residual
monitorin, when required
Unprotected cross-connections
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Finished Water Storage



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Inadequate internal cleaning and
maintenance of storage tank
Lack of proper screening of overflow pipes,
drains, or vents
Storage tank roofs or covers need repair
(e.g., holes or hatch or improper
construction)
Excessive water age in finished water
storage tanks
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Pumps, Pump Facilities,
and Controls



Inadequate pump capacity
Inadequate maintenance
Inadequate/inoperable control
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Monitoring, Reporting,
and Data Verification
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
Failure to properly monitor water
quality
Failure to meet reporting requirements
Inadequate recordkeeping
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System Management
Operation

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
Lack of approved emergency response
plan
Failure to meet water supply
demands/interruptions of service (e.g.,
unreliable water auxiliary power)
Inadequate follow-up to deficiencies
noted in previous assessment/survey
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Operator Compliance with
State Requirements

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Lack of operator training
Operator is not certified as required by
primacy agency
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New Sources
New sources coming online after
November 30, 2009 are required to:
OR
Complete source
water monitoring
as required by GWR
Provide 4-log
treatment of viruses
and conduct
compliance
monitoring within 30
days of source being
put in service
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What are the Corrective Action Requirements?
Corrective Action Options:
1)
2)
3)
4)
Correct all significant deficiencies.
Provide an alternate source of water.
Eliminate the source of contamination.
Provide treatment that reliably achieves at
least 4-log treatment of viruses (using
inactivation, removal, or a state-approved
combination of 4-log inactivation and
removal) before or at the first customer
for the GW source.
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Corrective Action Timeline
Event
Within 30 Days*
*Based on date of event.
Notice of significant
deficiency
OR
Notice from the lab of fecal
indicator-positive sample
from triggered or
assessment source water
monitoring
OR
Notice from the lab of fecal
indicator-positive sample from at
least 1 of 5 additional source
water monitoring samples
Within 120 Days*
State/regulatory
agency specifies
corrective action
OR
System consults
state/regulatory
agency to determine
corrective action
System must complete
corrective action plan
OR
System must be in
compliance with
state/regulatory agencyapproved corrective
action plan and schedule
Systems must take one or more of
the 4 corrective actions
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Treatment Technique Requirements


A state may require corrective action in
response to an initial fecal indicator positive
sample from a triggered source water
monitoring sample, triggered monitoring at a
wholesale system, or assessment monitoring.
A water system using a mixture of SW and GW
may not be required to take corrective action if
the state/regulatory agency determines that a
significant deficiency is in a part of the
distribution system served solely by SW.
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Treatment Technique Requirements
The PWS must consult with the state/regulatory
agency for appropriate corrective action to be
taken within 30 days if the regulator does not
designate a specific corrective action.
– The PWS must complete the corrective action or
be in compliance with a state/regulatory agency
approved corrective action plan and schedule,
within 120 days of the initial notification.
– The state/regulatory agency may require action
sooner than the 120 days, or require interim
measures to protect public health while the
water system is completing the corrective action.
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Path #2
If you have 4-log removal…
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Understanding “log”

For training, log refers to percent of viruses that
are removed or inactivated by treatment:
Log
0.5-log
1-log
2-log
3-log
4-log
5-log
% removal/inactivation
68.4%
90%
99%
99.9%
99.99%
99.999%
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What is Compliance Monitoring?

A GW source is not required to meet the source water
monitoring requirements of the GWR if it has at least 4log treatment (99.99 percent treatment) for viruses.

For existing sources that have the required treatment,
systems must notify and receive approval from the state
by December 1, 2009

Systems must notify the state as new systems are
brought on line that have this level of treatment.

Systems must conduct compliance monitoring that varies
with the type of treatment process used to meet 4-log
treatment of viruses, to monitor the effectiveness and
reliability or treatment.
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Understanding “log”



“log” refers to the percentage of viruses that treatment remove or
inactivate.
0.5-log is equivalent to 68.4% removal/inactivation; 1-log is equivalent to
90%; 2-log is equivalent to 99%; 3-log is equivalent to 99.9%; 4-log is
equivalent to 99.99%; 5-log is equivalent to 99.999%.
Treatment technologies capable of providing at least a 4-log treatment of
viruses include the following:
– Inactivation, with a sufficient disinfection concentration and contact time,
through disinfection with chlorine, chlorine dioxide, or ozone. Disinfectant
concentration and contact time (CT) can be based on existing CT tables or
state-approved alternatives.
– Removal with membrane technologies with an absolute molecular weight cutoff (MWCO), or an alternate parameter that describes the exclusion
characteristics of the membrane, that can reliably achieve at least a 4-log
removal of viruses.
– Inactivation, removal or combination of inactivation and removal through
alternative treatment technologies (e.g., ultraviolet radiation (UV)) approved
by the state, if the alternative treatment technology, alone or in combination
(e.g., UV with filtration, chlorination with filtration), can reliably provide at least
4-log treatment of viruses.
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Compliance Monitoring Options
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Alternative Treatment
Technologies


Systems may use alternative treatment
technologies, alone or in combination, that:
– Reliably provide 4-log treatment of viruses
AND
– Are approved by the state/regulatory
agency
Systems that use alternative treatment
technologies must:
– Monitor according to state/regualtory
agency-specified monitoring requirements
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Systems Serving <3,300
People
Using Chemical Disinfection

Systems must:
– Take daily grab samples
OR
– Meet all the continuous monitoring
requirements described for systems serving
more than 3,300 people
AT
– A location approved by the state/regulatory
agency

If the disinfectant residual falls below the
minimum concentration, the system must:
– Take samples every 4 hours until the residual
meets the required level
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Systems Serving >3,300
People
Using Chemical Disinfection

Systems must:
– Monitor the residual disinfectant concentration
continuously


At a location approved by the state/regulatory agency
(e.g., entry point)
– Record the lowest daily value for residual
disinfectant concentration
– Maintain a state/regulatory agency-determined
minimum disinfectant residual
If continuous monitoring equipment fails, a system
must:
– Collect grab sample every 4 hours
– Repair equipment within 14 days
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Systems Using Membrane
Filtration

Systems using membrane filtration for 4-log
treatment of viruses must meet statespecified requirements for:
– Monitoring the membrane
filtration process
– Operating the
membrane filtration
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Discontinuing 4-log Treatment of
Viruses

A GWS may discontinue providing 4-log
treatment of viruses if:
– The state determines it is no longer necessary
AND
– The system conducts triggered source water
monitoring

States must document and maintain records
of the determination
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Treatment Technique Violations
Violation occurs after
120 days if:
GWS with significant
deficiency does not
correct deficiency or
is not in compliance
with corrective action
plan
OR
GWS with fecal indicatorpositive source water
sample (not invalidated
by regulator) does not
complete corrective
action or is not in
compliance with
corrective action plan
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Treatment Technique
Violations
GWSs conducting compliance monitoring
(including state/regulatory agency specified monitoring) that:
AND
Fail to maintain at
least 4-log
treatment of
viruses at or before
the first customer
Fail to correct
within 4 hours
Must issue a Tier 2 notice to the public
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Monitoring Violations
Can result from failure to adhere to:
Additional source
Triggered source
water monitoring
requirements
water monitoring
requirements
OR
Assessment
source water
monitoring
requirements
Compliance
monitoring
requirements for
GWSs using 4-log
treatment
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What Are the Compliance Dates?
PWS Requirements
Required Beginning:
Triggered source water monitoring
Corrective actions
Compliance monitoring
New sources placed in service must meet triggered source
water monitoring requirements or provide 4-log treatment of
viruses
December 1, 2009
States can require GWSs to conduct assessment source water
monitoring
Required By:
Notification of 4-log treatment of viruses
State Requirements
December 1, 2009
Required By:
Complete sanitary surveys for most CWSs
December 31, 2012
(and every 3 years after)
Complete sanitary surveys for NCWSs and remaining CWSs
December 31, 2014
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(and every 5 years after)
Reporting and recordkeeping for systems:

GW systems conducting compliance monitoring must notify the
state by the end of the next business day any time the system fails
to meet state-specified requirements for disinfectant residuals,
membrane operating, etc.

Water systems completing corrective action must notify the state
within 30 days.

Water systems must maintain records of:
•
•
•
•
Corrective Actions (not less than 10 years)
Public Notice (not less than 3 years)
Sample Invalidation (not less than 5 years)
Records related to performance of compliance monitoring (not less
than 10 years)
• Consecutives (not less than 5 years)
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• Lowest daily disinfectant level (not less than 5 years)
• State Reporting Requirements (not less than 5 years)
Special Notice (SN)


Special Notice is separate from and in
addition to PN and the CCR.
Circumstances that require SN differ for
CWS and NCWSs.
- CWSs may make SN in their CCR
- FI+ not invalidated by the state
- Annually until SD is corrected
- NCWSs must prepare and distribute
SN in a manner approved by the state.
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Mandatory Health Effects Language
“Fecal indicators are microbes whose
presence indicates that the water may be
contaminated with human or animal
wastes. Microbes in these wastes can
cause short-term health effects, such as
diarrhea, cramps, nausea, headaches, or
other symptoms. They may pose a
special health risk for infants, young
children, some of the elderly, and people
with severely compromised immune
systems.”
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Public Notification Summary –
Tier 1
Situation or Violation
Source water monitoring sample
fecal indicator-positive for E. coli,
enterococci, or coliphage and not
invalidated by the state
Report
Notify
to
Public1
State
Within
24
Hours
Within
24
Hours
PN Method
TV, hand-delivery,
public postings, or
other state-approved
method (consult your
state)
1. Systems are required to send a copy of the PN to the state within 10
days of making the notification.
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Public Notification Summary –
Tier 2
Situation or Violation
Report
to State
Notify
Public1
PN Method
Within
30 Days
Hand-delivery,
direct mail, public
postings,
newspaper or
radio
announcements
Failure to complete required
corrective action
Failure to comply with a stateapproved correction schedule and
plan 2
For systems conducting
compliance monitoring, failure to
maintain 4-log treatment of
viruses and restore 4-log
treatment within 4 hours 2
Within
48 Hours
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50
Public Notification Summary – Tier 2


1. Systems are required to send a copy of the PN to
the state within 10 days of making the notification.
2. Community GWSs with an uncorrected significant
deficiency must report it in the appropriate CCR. Those
systems are also required to report any fecal indicatorpositive samples in the appropriate CCR. They are
required to inform the public annually until the state
determines that the particular significant deficiency or
fecal contamination in the ground water source has
been addressed.
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Public Notification Summary –
Tier 3
Situation or Violation
Failure to conduct required
source water monitoring
(triggered, additional, or
assessment)
Failure to conduct required
compliance monitoring
Report
to
State
Notify
Public1
Consult
your
state
CCR 2
Within (consult your
12
state for other
Months
specific PN
requirements)
PN Method
1. Systems are required to send a copy of the PN to the state within 10 days of making the
notification.
2. The CCR requirement applies to CWS. NCWSs must use an alternate form of Tier 3
notice approved by their state.
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Key Points to Take Away









Begin compliance on 12/1/09
Applies to all system’s sources not following SWTR
If not using 4-log, and you get a TCR+, the GWR is
“triggered”
Sampling is in addition to TCR requirements
Sanitary Surveys will “be tougher”
If your PWS has multi sources, consider a Representative
Source Water Monitoring Plan
Corrective actions required by GWR
Notify inspector if adding/discontinuing 4-log treatment
Call ADEQ/MCESD if you get a positive total coliform.
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Guidance Documents Available:
Go to the ADEQ website, Ground Water Rule page:
http://www.azdeq.gov/environ/water/dw/gw_rule.html
The ADEQ webpage will be updated with ADEQ contact
information, applications and reporting forms (as they
are developed), and links to EPA’s website for
guidance documents and quick reference guides.
For more information:
Donna Calderon, Manager
Drinking Water Monitoring and Protection Unit
602-771-4641 or [email protected]
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